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expenses” includes expenses for certain dependent care centers.
Sec. 21(b)(2)(A), (C), (D).
In the present case, petitioner claimed the credit under
section 21(a) with respect to Jaleshia for 1999. We have
concluded that petitioner was entitled to dependency exemption
deduction for Jaleisha for that taxable year, and thus, Jaleshia
is a qualifying individual. However, petitioner could not and
did not substantiate that he incurred any employment-related
expenses within the meaning of section 21(b)(2), and evidence in
the record suggests that the dependent care center was no longer
in operation during 1999. Accordingly, petitioner is not
entitled to the credit for child and dependent care expenses for
1999. We sustain respondent’s determination on this issue.
6. Charitable Contribution Deductions
Section 170(a)(1) allows as a deduction a charitable
contribution payment of which is made within the taxable year. A
charitable contribution includes a contribution or gift to or for
the use of a corporation, trust, community chest, fund, or
foundation organized and operated exclusively for religious,
charitable, scientific, literary, or educational purposes. Sec.
170(c)(2)(B).
If a taxpayer makes a charitable contribution in cash or by
check, the taxpayer shall maintain for each contribution either a
canceled check, a receipt or letter from the donee charitable
organization, or other reliable written records showing the name
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